SecProbe.io

December 18, 2024
Fufei Lin
Chief Executive Officer
Aigo Holding Ltd
4th floor, Building No. 26, Ju Yuan Zhou Garden
Jinshan Industrial Zone, 618 Jinshan Avenue, Jianxin Town
Fuzhou City, Fujian Province, China 350028
Re:Aigo Holding Ltd
Amendment No. 4 to Draft Registration Statement on Form F-1
Submitted December 6, 2024
CIK No. 0002025255
Dear Fufei Lin:
            We have reviewed your amended draft registration statement and have the following
comment(s).
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 4 to Draft Registration Statement on Form F-1 submitted December 6, 2024
Risk Factors
Risks Related to Our Business and Industry, page 16
Your results of operations disclosure for the nine months ended September 30, 2024
indicates that cost of revenues increased and gross profit margin decreased "mainly
because the significant increase of the shipping clearance fee" and that such fee
increased "due to the impact of the situation in the Red Sea." Please update your risk
factor disclosure where appropriate if recent supply chain disruptions have impacted
your operations. Describe how you have been impacted and any mitigation efforts
undertaken. If the disruptions represent a known trend or uncertainty that may 1.

December 18, 2024
Page 2
continue to materially impact your financial condition or results of operations in
future periods, address them in further detail in MD&A pursuant to Item 5 of Form
20-F as well.
Capitalization, page 49
2.Please tell us your consideration of including short-term borrowings and amounts due
to related parties in your calculation of total capitalization. Refer to Item 3.B of Form
20-F.
Financial Statements, page F-1
3.Please revise the statement headers for your period ended September 30, 2024 to mark
the statements and related notes as unaudited, here and on the individual pages where
the statements are presented.
Consolidated Statements of Cash Flows, page F-6
4.The parenthetical header on your statements of cash flows provided on pages F-6 and
F-33 state the amounts are presented in RMB. However, your financial statements
appear to be presented in EUR.  Please revise, or advise.
General
5.We note your disclosure regarding the August 2024 agreement pursuant to which your
Hong Kong subsidiary Aigoleo Limited will acquire all equity interests of Arteconfort
Hoteles S.L. Where you discuss this agreement, please describe all material terms,
including the purchase price to be paid for this entity. Clarify whether and how this
acquisition is related to your disclosure at page 47 that approximately 20.0% of the
offering proceeds may be used for "potential acquisitions of, or investments in, other
businesses of technologies." If any proceeds from this offering will be used to finance
the acquisition of Arteconfort Hoteles S.L., revise to disclose as much and provide the
information required by Item 3.C.3 of Form 20-F. Lastly, to the extent this acquisition
represents a change to or expansion of your principal business activities, please revise
where appropriate in your business disclosure to describe the products or services to
be offered through this entity.
            Please contact Abe Friedman at 202-551-8298 or Theresa Brillant at 202-551-3307 if
you have questions regarding comments on the financial statements and related
matters. Please contact Rebekah Reed at 202-551-5332 or Dietrich King at 202-551-8071
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Yu Wang